John Timperio

John Timperio

Dechert LLP

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Credit Risk Retention Final Rule: Enforcement and Compliance Considerations

Predicting enforcement of the final rule regarding U.S. risk retention is an uncertain task. This OnPoint is designed to provide guidance on possibilities related to consequences of non-compliance, enforcement approaches by...more

12/16/2014 - Asset-Backed Securities CMBS Collateralized Loan Obligations Dodd-Frank Enforcement Guidance Final Rules Private Right of Action Prudential Regulation Authority Risk Retention

U.S. Risk Retention Final Rule: Playing it Forward for CLOs

We will leave the hand wringing and teeth gnashing to others. We expect there will be a lot of that in the days ahead. We have had our say on the misguided premises and tortured statutory interpretation underpinning the final...more

10/23/2014 - Collateralized Debt Obligations Collateralized Loan Obligations Dodd-Frank FDIC Risk Retention Securities Exchange Act Volcker Rule

Old Wine in New Bottles: The Emergence of the P2P Small Business Lending Securitizations

This last year has seen an uptick in activity in the peer to peer commercial loan market in the U.S., which, broadly speaking, includes loans made by non-traditional financing sources to small businesses (“P2P Commercial...more

8/27/2014 - Funding Hedge Funds Loans Peer-to-Peer Popular Securities Securitization Securitization Market Small Business Startups

European Commission Publishes Final Regulatory Technical Standards on Risk Retention

The European Commission published the final regulatory technical standards on 13 March 2014 specifying the requirements for investor, sponsor, original lenders and originator institutions relating to exposures to transferred...more

3/26/2014 - EU European Commission Risk Retention

Volcker Rule Regulations Issued: Understanding the Practical Implications for U.S. and Foreign Banking Entities, Funds and...

The Volcker Rule (“Volcker Rule” or “Rule”) is intended to limit risks to the financial system that Congress believes may be created by (i) proprietary trading operations of insured depository institutions, foreign banking...more

1/22/2014 - Banking Sector Collateralized Debt Obligations Dodd-Frank Financial Regulatory Reform Hedge Funds Proprietary Trading Trust Preferred Securities Volcker Rule

CLOs Under the Volcker Rule: New Exemptions, New Issues, New Obligations

Under the final version of the Volcker Rule issued this week, issuers and sponsors of new CLO issuances should consider structuring CLOs to conform to the exclusions contained in the rule, and banks and bank affiliates that...more

12/17/2013 - Bank Holding Company Banking Sector Collateralized Loan Obligations Derivatives Dodd-Frank FDIC Federal Reserve Financial Regulatory Reform Hedge Funds Investment Fund Vehicles Investment Funds Leveraged Loans Loans Private Equity Funds Reporting Requirements Secured Loans Volcker Rule

Risk Retention Reproposal’s Impact on CLOs: Loan Arrangers Get Invited to the Party that No One Wants to Attend

CLO managers and lead arrangers of syndicated loans received special attention in a proposal jointly released by six federal agencies to implement the credit risk retention requirements of Section 941 of the Dodd-Frank Act....more

8/31/2013 - Collateralized Loan Obligations FDIC Federal Reserve FHFA HUD OCC Proposed Regulation Risk Retention SEC Securitization

EBA Consultation Paper Raises Concerns for CLOs

The European Banking Authority (EBA) published a consultation paper on draft technical standards relating to the implementation of CRD IV on 22 May 2013. Of particular concern to participants in the CLO market are the...more

5/24/2013 - Capital Requirements Consultation European Banking Authority

New FDIC Rules on “Higher Risk Securitizations” and the Impact on CLOs: The Teapot Tempest

The Federal Deposit Insurance Corporation’s (“FDIC”) new rules for calculating deposit insurance assessments for large institutions and highly complex institutions (some of which have been active investors in collateralized...more

3/22/2013 - Collateralized Loan Obligations Dodd-Frank FDIC Higher-Risk Securitizations Risk Assessment

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